United States Tax Court January 2, 2001, 17251-98 (Colorado Gas Compression, Inc. v. Commissioner)

116 T.C. No. 1

UNITED STATES TAX COURT

COLORADO GAS COMPRESSION, INC., Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 17251-98. Filed January 2, 2001.

P became an S corp. in 1988, a C corp. in 1989,

and an S corp. in 1994. In 1994, 1995, and 1996,

petitioner sold assets which had accrued gain prior to

the 1994 conversion from C to S corp. status.